June 1, 2021

The Honorable Pete Buttigieg 

U.S. Secretary of Transportation 

1200 New Jersey Ave, SE 

Washington, DC 20590 

Dear Secretary Buttigieg, 

The Metrics and Minimum Standards for Intercity Passenger Rail Service final rule published by the 

Federal Railroad Administration (“FRA”) on November 16, 2020 (the “Final Rule”), introduces a 

certified schedule metric that requires the FRA to report the number of certified Amtrak schedules, 

uncertified schedules, and disputed schedules, by train, route, and host railroad. 

The Final Rule defines a “certified schedule” as a published Amtrak train schedule that Amtrak and the 

host railroad jointly certify is aligned with the customer on-time performance (“OTP”) metric and 

standard set forth in the Final Rule. 

Pursuant to the requirements of the Final Rule, Amtrak and New Mexico Department of Transportation 

(NMDOT) are transmitting this letter regarding the following schedules that remain uncertified as of May 

17, 2021, as agreement has not been reached on whether the schedule is aligned to customer OTP: 

1. Southwest Chief Trains 3 and 4. 

Exhibit A details Amtrak’s position regarding the components of the train schedules which are disagreed 

upon, signed by me. 

Exhibit B details NMDOT’s position regarding the components of the train schedules which are disagreed 

upon, signed on behalf of NMDOT Cabinet Secretary Michael Sandoval by Justin Reese of that 

department.

AMTRAK

1 Massachusetts Avenue, NW, Washington, DC 20001

Email william.flynn@amtrak.com Tel 202-906-3963 

William J. Flynn

Chief Executive Officer
The Honorable Pete Buttigieg

June 1, 2021

Page 2

Amtrak and NMDOT continue to meet regularly and hope to come to an agreement on the certification of 

all schedules no later than September 30, 2021. Please let us know if you have any questions regarding 

the information provided in this transmittal.

Sincerely,

William J. Flynn

Chief Executive Officer

Attachments 

cc: The Honorable Martin J. Oberman, Chairman, Surface Transportation Board 

 The Honorable Peter A. DeFazio, Chair, Committee on Transportation and Infrastructure, U.S. 

House of Representatives

 The Honorable Sam Graves, Ranking Member, Committee on Transportation and Infrastructure, 

U.S. House of Representatives 

 The Honorable Maria Cantwell, Chair, Committee on Commerce, Science, and Transportation, 

U.S. Senate 

 The Honorable Roger Wicker, Ranking Member, Committee on Commerce, Science, and 

Transportation, U.S. Senate

 The Honorable Rosa L. DeLauro, Chair, Committee on Appropriations, U.S. House of 

Representatives

 The Honorable Kay Granger, Ranking Member, Committee on Appropriations, U.S. House of 

Representatives

 The Honorable Patrick Leahy, Chair, Committee on Appropriations, U.S. Senate 

 The Honorable Richard Shelby, Ranking Member, Committee on Appropriations, U.S. Senate 

 The Honorable Pete Aguilar, U.S. House of Representatives 

 The Honorable Nanette Diaz Barragán, U.S. House of Representatives 

 The Honorable Karen Bass, U.S. House of Representatives

 The Honorable Michael Bennett, U.S. Senate 

 The Honorable Roy Blunt, U.S. Senate 

 The Honorable Ken Buck, U.S. House of Representatives 

 The Honorable Cheri Bustos, U.S. House of Representatives 

 The Honorable Ken Calvert, U.S. House of Representatives 

 The Honorable Sean Casten, U.S. House of Representatives 

 The Honorable Judy Chu, U.S. House of Representatives 

 The Honorable Emanuel Cleaver, U.S. House of Representatives 

 The Honorable Lou Correa, U.S. House of Representatives

 The Honorable Sharice Davids, U.S. House of Representatives 
The Honorable Pete Buttigieg

June 1, 2021

Page 3 

 The Honorable Danny Davis, U.S. House of Representatives 

 The Honorable Tammy Duckworth, U.S. Senate 

 The Honorable Dick Durbin, U.S. Senate 

 The Honorable Joni Ernst, U.S. Senate 

 The Honorable Ron Estes, U.S. House of Representatives 

 The Honorable Dianne Feinstein, U.S. Senate 

The Honorable Teresa Leger Fernandez, U.S. House of Representatives

 The Honorable Bill Foster, U.S. House of Representatives 

The Honorable Jesús García, U.S. House of Representatives

 The Honorable Jimmy Gomez, U.S. House of Representatives 

 The Honorable Paul Gosar, U.S. House of Representatives 

 The Honorable Chuck Grassley, U.S. Senate 

The Honorable Josh Hawley, U.S. Senate 

 The Honorable Martin Heinrich, U.S. Senate 

 The Honorable Yvette Herrell, U.S. House of Representatives 

 The Honorable John Hickenlooper, U.S. Senate 

 The Honorable Robin Kelly, U.S. House of Representatives

 The Honorable Young Kim, U.S. House of Representatives 

 The Honorable Adam Kinzinger, U.S. House of Representatives 

 The Honorable Darin LaHood, U.S. House of Representatives 

The Honorable Jake LaTurner, U.S. House of Representatives

The Honorable Ted Lieu, U.S. House of Representatives 

 The Honorable Ben Ray Luján, U.S. Senate 

 The Honorable Tracey Mann, U.S. House of Representatives 

 The Honorable Roger Marshall, U.S. Senate 

The Honorable Marianette Miller-Meeks, U.S. House of Representatives

 The Honorable Jerry Moran, U.S. Senate 

The Honorable Marie Newman, U.S. House of Representatives

 The Honorable Jay Obernolte, U.S. House of Representatives 

 The Honorable Tom O'Halleran, U.S. House of Representatives 

 The Honorable Alex Padilla, U.S. Senate 

 The Honorable Mike Quigley, U.S. House of Representatives 

 The Honorable Lucille Roybal-Allard, U.S. House of Representatives 

 The Honorable Bobby Rush, U.S. House of Representatives 

 The Honorable Linda T. Sánchez, U.S. House of Representatives

 The Honorable Janice Schakowsky, U.S. House of Representatives 

 The Honorable Adam Schiff, U.S. House of Representatives 

 The Honorable Kyrsten Sinema, U.S. Senate 

 The Honorable Mark Takano, U.S. House of Representatives 
The Honorable Pete Buttigieg

June 1, 2021

Page 4 

 The Honorable Norma Torres, U.S. House of Representatives 

 The Honorable Lauren Underwood, U.S. House of Representatives 

 The Honorable Maxine Waters, U.S. House of Representatives
Exhibit A

Amtrak’s position regarding the disagreed upon components of the train schedules.

The Final Rule defines a “certified schedule” as a published train schedule that Amtrak and the host railroad 

jointly certify is aligned with the customer on-time performance (“OTP”) metric and standard set forth in 

the Final Rule. In order to determine whether a train schedule is aligned with the customer OTP metric, 

Amtrak developed an analytical framework to review each schedule and its alignment with the customer 

OTP metric. Fundamentally, the analytical framework confirms whether the schedule works to minimize 

passenger delay while giving riders the greatest opportunity to arrive at their destinations on-time. Several 

criteria, listed below, were rigorously analyzed to determine whether the schedule was appropriately aligned 

to the customer OTP metric.

1. Prior Customer OTP Schedule Modifications. If Amtrak and the host railroad previously 

agreed to modify the schedule to align with customer OTP, and no significant changes in 

passenger deboarding patterns were evident since that agreement, that schedule was determined 

to be aligned with the customer OTP metric. 

2. Strong Historical Performance. While certification directly relates to the schedule, not actual 

performance, if a train has regularly exceeded the minimum standard 80% customer OTP, that 

schedule was deemed to be aligned with the customer OTP metric. 

3. Recovery Time-Ridership Correlation. Amtrak performed a regression analysis for each 

schedule to calculate the correlation between the placement of recovery time in the schedule and 

the number of detraining riders at each station. If the regression result was strong (0.5 or more), 

the train schedule was determined to be aligned with the customer OTP metric. 

4. Recovery Time Distributed to Passenger Benefit. Amtrak developed a measurement of the 

schedule’s recovery time distribution to determine whether that time is effectively placed to help 

passengers. If the recovery time is placed in advance of detraining passengers to help them arrive 

on-time, then, based on a consistent calculation for all trains, the schedule was determined to be 

aligned with the customer OTP metric.

Table 1 lists each uncertified train schedule by service and notes which criteria were met for each schedule

that led to Amtrak’s determination that the schedule is aligned with customer OTP. Amtrak looks forward 

to continuing to work with New Mexico Department of Transportation to certify the following schedules.

Sincerely,

William J. Flynn

Chief Executive Officer

Amtrak
Table 1: Amtrak Schedule Alignment Analysis Results by Train

Service Train

Train OriginDestination 

1. Prior Customer 

OTP Schedule 

Modifications

2. Strong Historical 

Performance 

3. Recovery TimeRidership 

Correlation

4. Recovery Time 

Distributed to 

Passenger Benefit 

Assessment based on 

Criteria

Southwest 

Chief

3 Chicago-Los 

Angeles

Yes √ √ Aligned to Customer OTP

Southwest 

Chief

4 Chicago-Los 

Angeles

Yes √ Aligned to Customer OTP